February 29, 2024

Responsible Sourcing Newsletter: February 2024

Be Curious! LBMA Answers Your Questions

Last month, we announced the launch of “Ask Responsible Sourcing”, where LBMA Members and readers were invited to pose whatever burning questions they would like answered.

Not to be too Socratic about things, but I am a firm believer that there are no wrong or “stupid” questions, as only through asking does one find the proverbial enlightenment one seeks or requires. We are also big fans of Ted Lasso, and very much guided by his call that we all “be curious, not judgemental.”

It should also be said that this new initiative serves several useful and selfish purposes for our team. Most importantly it opens up a new avenue of dialogue with a critically important demographic - GDL Refiners, Approved Service Providers, civil society organisations and the broader public that has an interest in the gold ecosystem. It also gives us an indication of what issues are important to you, as well as a sense of where we might need to do a better job communicating things that we consider second nature or take for granted.

Before we get to the questions, we want to thank all those who took the time to submit questions for our consideration. Each month, we will endeavour to pick a few to answer. So please, Be Curious, and keep sending us your questions.

For the inaugural edition of “Ask Responsible Sourcing”, we chose two questions focussed on due diligence.

“I have had great difficulty identifying a list of territories that fall foul of child labour practice, money laundering, conflict funding, or mining safety standards, and how these each are framed.” - A Refiner

Answer: LBMA purposely does not have a Conflict Affected and High Risk Area (CAHRA) List, because it is the responsibility of the Refiner to demonstrate they have undertaken credible and sufficient due diligence of their supply chain. However, the Responsible Gold Guidance (RGG) does outline resources that can assist Refiners in identifying such risks (see p. 22, for example).

There is no single, one-stop source that will give you answers to the broad spectrum of possible risks in your supply chain. Go above and beyond just the sources outlined in the RGG. In addition to the European Union’s CAHRA list, for example, consult those of Tdi, or other industry partners and jewellery groups. In addition to the Heidelberg Barometer, consider conflict databases managed by the Stockholm International Peace Research Institute (SIPRI), or the services of risk firms that provide tailored conflict and political economy assessments that can highlight potential reputational jeopardy.

NGO reports, as well as those of the UN Groups of Experts and specialist think-tanks like the International Crisis Group or Chatham House, can be invaluable sources of information in identifying areas, trade routes, corporate entities and individuals involved in conflict financing or money laundering. The International Labour Organisation is a go-to resource on child labour. The Antwerp-based IPIS just published a fascinating interactive map of mining and conflict in Eastern Congo.

The use of Google searches and alerts, tailored to both the country, risk and entity from which material is sourced, is another simple and useful way to gather and monitor publicly available news and information.

LBMA’s Sourcing Watch, that highlights serious market concerns, may provide further awareness to GDL Refiners.

“When working in [Country A] with suppliers throughout the world, do you think that the accurate assessment of [Country A’s] human rights situation and child labour practices can genuinely categorize [Country A] as a supplier with minimal risk?” - An Assurance Provider

Answer: Whereas Refiners have the responsibility to determine the risk level of their supply chain (and apply a level of due diligence and mitigation commensurate with any identified risks), the Assurance Provider’s role is to challenge the Refiner to justify their risk assessment until they have comfort with their answers and rationale.

Country A may well have a poor human rights record or presence of child labour, but that in and of itself is not necessarily grounds for disengagement or concern. What matters is whether, and how, such risks intersect with a Refiner’s supply chain.

For example, two refiners sourcing from the same country may well have two entirely different risk profiles. One that sources from an industrial miner with a closed supply chain, robust security measures, no presence of child labour within or near its concession will have a lower risk level than another that takes material from an aggregator that sources from multiple suppliers, including scrap metal dealers or artisanal miners, who often have a closer proximity to illegality and criminal elements.

Focus on understanding the Refiner’s supply chain and its associated risks, rather than the risk profile of the country itself.

Ask Responsible Sourcing

Don't forget to ask whatever burning questions you may have about all facets of responsible sourcing.

Responsible Sourcing-related questions can be submitted using this form or scanning the QR code. Questions will be published (on an anonymised basis) with answers appearing in the next Newsletter.

There are no wrong questions but please note this newsletter is published the last Thursday of each month, so send your questions well in advance to ensure there is enough time to give them the appropriate consideration.

We look forward to hearing from you.

Sustainability & Responsible Sourcing Summit 2024

The Summit is still almost three weeks away but we have already started the countdown. With the agenda and speaker line up agreed, we very much hope you will be able to join us at the Hilton London Tower Bridge from Wednesday, 20 to Friday, 22 March.

This event, hosted by LBMA and World Gold Council, is an opportunity for industry players and stakeholders across the precious metals value chain to explore the role of responsible sourcing beyond the lens of ethical sourcing, with discussions also covering the rapidly developing sustainability agenda.

The agenda will explore collaboration and convergence of climate plans and actions in the gold supply chain. There will be discussion around structural change in the ASM sector, in particular exploring the improvement of ESG standards and sourcing practices in this sector. Participants will also have the opportunity to hear about efforts by industry members to adapt to the evolving sustainability landscape.

Alan Martin
Head of Responsible Sourcing, LBMA

Responsible Sourcing News

Asia and Middle East

  • Bid to mitigate gold mine’s impact on orangutans hit by stonewalling, data secrecy. Mongabay
  • Missing Turkish miners ‘swallowed by cyanide-laced landslide’. The Guardian
  • Hong Kong customs arrests Macau chauffeur after seizing gold bars worth HK$10 million hidden inside his car. South China Morning Post


  • Top producers push for silver’s inclusion as a critical mineral in Canada and US. The Northern Miner
  • Gold fever: big mining companies circle as El Salvador prepares to reverse ban. The Guardian
  • Brazil prosecutors seek annulment of contract for Belo Sun gold mine. Reuters
  • Mexican president proposes ban on open-pit mining. Mining.com
  • Consultation starts in Guatemala over future of Pan American Silver’s Escobal mine: Mining.com
  • ‘Dirty political games’: Suriname is selling its gold and timber – at the cost of tribal land rights. The Guardian


  • Activists Sue LME for ‘Ignoring Environmental Impact of Metals’. Bloomberg
  • Russia’s Wagner 2.0 takes over security and gold mines in Africa. inews
  • Expedition to 300-year-old shipwreck that could hold Spanish treasure of gold and emeralds worth $20 billion. Business Insider


  • Balancing environmental and social responsibility with economic growth and evolving environmental mining regulations. Mining Review Africa
  • Can SA mining prevent more hostage dramas in 2024? Mining Weekly
  • Three dead as bus carrying B2Gold employees attacked in Mali. Reuters
  • Burkina Faso suspends export permits for small-scale gold production. Mining.com


  • ‘We need information’: researchers rank Australia sixth in the world for missing mining data. The Guardian
  • Threat of climate change has transformed the image of mining. Mining Weekly
  • ICMM announces initiative to simplify responsible mining standards. Mining Weekly
  • Gold mining industry striving to build on sustainability strides. Mining Weekly

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